Hi Folks
We have been into this subject in some detail as we supply a lot of
equipment into this market.
The situation varies enormously between Directives - there is certainly not
a common approach in the New Approach Directives.
Our current reading of the situation is
LVD
- No exemptions in the Directive, and certainly not in implementing UK
legislation, or in that of any other EU country of which we have heard.
EMC
- No exemption in the Directive, but exemptions in some national
legislation, e.g. the UK Electromagnetic Compatibility Regs 1992, Clause 20.
i.e:
"Military equipment
20.-(1) These Regulations do not apply to military equipment.
(2) In this regulation, "military equipment " means apparatus which is
designed for use as arms, munitions and war material within the meaning of
Article 223.1(b) of the Treaty establishing the European Economic Community
(notwithstanding that it may be capable of other applications), but does not
include apparatus which is designed both for such use and for other
applications."
Note: Note the use of the word "designed for" - which might be interpreted
as meaning that equipment designed for military use can be used elsewhere
and yet still be excluded!
We have heard that there are exemptions in most other EU countries, notably
and - at one time - the draft European standard for "dual pupose equipment"
{CENELEC CLC/TC210(SEC)35/36 (BS Draft for Public Comment 97/200728) "EMC
Conformity of Equipment Designed for Military and Other Purposes" identified
Germany/Austria/Norway as not having exemptions. We think that the situation
has changed (especially for Germany) but we are still seeking proof.
R&TTE Directive
- Exemptions in the Directive in Article 1 "Scope and aim" sub-para 5 "This
Directive shall not apply to apparatus exclusively used for activities
concerning public security, defence, State security (including the economic
well-being of the State in the case of activities pertaining to State
security matters) and the activities of the State in the area of criminal
law."
Note: This refers to equipment "used" for these purposes, whether or not it
was designed for them!
Machinery Directive
- Exemptions in Directive in Article 1. Sub-article 3 " machines specially
designed and constructed for military or police purposes"
Note: This looks like the UK exemption from the EMC Directive - and quite
different from the R&TTE Directive!
General Note:
In general, note the "exclusivity" clauses do not exclude equipment for
"dual-use" (military and non-military") as this needs to comply for
non-military sales.
Hope this helps a bit.
HOWEVER, if anyone can fill in the situation on the national legislation -
notably for the EMC Directive - in countries with which they are familiar
then we would be most grateful.
Regards
John Allen, Thales Defence Communications, Bracknell UK
-----Original Message-----
From: Stewart, Judd [ mailto:stewart.jud...@sd.littonisd.com
<mailto:stewart.jud...@sd.littonisd.com> ]
Sent: 04 September 2001 18:16
To: 'EMC-PSTC'
Subject: Military Equimpment and the EU
Good morning!
I am faced with coming up with a regulatory strategy for equipment that
will be sold to a foreign military (member of the EU). The equipment is
entirely military and has military unique attributes. The products range
from battery operated hand held devices to laptops that can use a battery
adapter which plugs into the mains.
All units have LI-ION batteries and High voltage inverters for powering the
LCD backlight.
Some have a standard PCMIA card slot which will allow the user to install a
commercial modem if he chooses. We do not provide this card
I have reviewed the LVD and EMC directives and find no exclusion for
military equipment. Is there?
What other directives may be applicable?
Thanks in advance
Judd Stewart
Northrop Grumman
San Diego Calif.
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